Case Summary (G.R. No. 214241)
Summary of Facts
Upon delivery, the Bureau of Customs found that one box of the diesel engine parts was in bad order, with various items missing, valued at P1,076.43. The American Insurance Company, having compensated the consignee for the loss, sought recovery of this amount through a complaint filed on July 20, 1964, in the City Court of Manila. The City Court ruled in favor of the American Insurance Company, ordering the defendants to pay P1,076.43 along with legal interest from the date of filing.
Legal Proceedings and Argument
The Republic of the Philippines and the Bureau of Customs subsequently appealed the decision to the Court of First Instance. The defendants denied liability and raised the issue of non-suability, asserting that the Republic could not be sued without its consent and that the Bureau of Customs, as an agency of the government, lacked the capacity to be involved in a lawsuit. Following partial stipulations on the lost items, the Court of First Instance dismissed the case on January 13, 1966, supporting the defendants' claims.
Legal Question
The central legal question presented on appeal is whether the Republic of the Philippines and the Bureau of Customs can be sued under the circumstances of this case. The Supreme Court referenced the decision in Mobil Philippines Explorations, Inc. v. Customs Arrastre Service and Bureau of Customs, which established that the arrastre operations conducted
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Case Background
- The case involves a shipment by the SS "Toreador" which delivered one case of compressor parts and two boxes of diesel engine parts to the Bureau of Customs.
- The shipment originated from New York and was consigned to Bislig Bay Lumber Co.
- Upon delivery, the Bureau of Customs reported that one of the boxes containing various diesel engine parts was in bad order, with items missing, valued at P1,076.43.
- The American Insurance Company compensated the consignee for the loss incurred.
Procedural History
- On July 20, 1964, the American Insurance Company filed a complaint in the City Court of Manila seeking recovery of P1,076.43 as subrogee of the consignee against the Bureau of Customs and the Republic of the Philippines.
- The City Court ruled in favor of the plaintiff, ordering the defendants to pay the amount claimed with legal interest from the date of filing.
- The defendants appealed to the Court of First Instance, denying liability a